BlackRock Calls on U.S. OCC to Abandon Idea of Setting Cap on Tokenized Reserves

**May 3 Update** BlackRock has pushed back against proposed reserve asset restrictions tied to the OCC’s draft rules implementing the GENIUS Act, submitting a 17-page comment letter on the final day of the agency’s 60-day comment window (which opened March 2 when the draft published in the Federal Register). The OCC posed more than 200 questions spanning reserve composition, capital requirements, custody, and income restrictions. BlackRock’s comments center on rules governing **Permitted Payment Stablecoin Issuers (PPSI)**—entities authorized to issue stablecoins as federal-chartered firms last July after a Trump-signed law took effect. The firm is urging the OCC to scrap a proposed 20% limit on tokenized reserve assets for PPSI, arguing the cap is “irrelevant” to the agency’s regulatory goals. BlackRock notes risk hinges on an asset’s credit quality, duration, and liquidity—not whether it’s held or transferred via a distributed ledger. This position ties directly to BlackRock’s tokenization footprint: Its BUIDL Fund, one of the largest tokenized U.S. Treasury products, has ~$2.6 billion in AUM and backs over 90% of the reserves for Ethena’s USDtb and Jupiter’s JupUSD (Solana-based stablecoins), per RWA.xyz data. Circle’s USYC leads the space with ~$2.9 billion in AUM.